nrc-2009-0279-0038

Upload: loffegutt

Post on 02-Jun-2018

215 views

Category:

Documents


0 download

TRANSCRIPT

  • 8/11/2019 NRC-2009-0279-0038

    1/79

    NUREG/CR-6112

    BNL-NUREG-52394

  • 8/11/2019 NRC-2009-0279-0038

    2/79

  • 8/11/2019 NRC-2009-0279-0038

    3/79

    DISCLAIMER

    This repor t w a s prepared as a n a c c o u n t

    of work

    s pons o red

    by an agenc y of th e United Sta te s Government. Neither th e

    United States Government nor any agency thereof, nor any

    of thei r employees , ma ke an y warran ty , exp ress or implied ,

    or assumes any legal l iabil i ty

    or

    responsibility for the

    accuracy , comple teness , or usefu lness

    of

    any information,

    appara tus , p roduct , o r proce ss disclosed , or represents th a t

    its

    us e would not infringe privately own ed r ights . Referen ce

    herein to any speci f ic commercia l p roduct , p rocess , or

    serv ice by t rade name, t rademark , manufac turer , or

    o t h e r w i s e d o e s not necessarily constitute or imply

    its

    endorsement , recommendat ion , or favoring by the United

    States

    Government

    or

    any agency the reo f. The v iews and

    opinions of authors expressed here in do

    not

    necessari ly

    state or reflect t h o s e of th e United States Governmen t or

    any agency the reo f .

  • 8/11/2019 NRC-2009-0279-0038

    4/79

    DISCLAIMER

    Portions

    of

    this document m ay be illegible

    in electronic image products. Images are

    produced from th e best availabie original

    document.

  • 8/11/2019 NRC-2009-0279-0038

    5/79

    Abstract

    This report summarizes information required to estimate, at least qualiitively, the potential impacts of

    reducing occupational dose limits below those given in 10CFR 20 (Revised).

    For this study, a questionnaire was developed and widely distributed to the radiation protection commu-

    nity. The resulting data together with data from existing surveys and sources were used to estimate the

    impact of three dose-limit options; 10 mSv yr ' (1 remyr'),

    20

    mSv yrl

    (2

    rem yrl), and a combination of

    an annual limit of

    50

    mSv yrl

    (5

    rem yf') coupledwith a cumulative limit, in rem, equal to age in years.

    Due to the somewhat small number of responses and the lack of data

    in

    some specific areas, a working

    committee of radiation protection experts from a variety of licensees was employed to ensure the

    exposure data were representative.

    The following overall conclusions were reached:

    (1)

    Although 10 mSv yf ' is a reasonable limit for many licensees, such a limit could be extraordinarily

    difficult to achieve and potentially destructive to the continued operation of some licensees, such

    as nuclear power, fuel fabrication, and medicine.

    (2)

    Twenty mSv yrl as a limit is possible for some of these groups, but for othersitwould prove

    difficult.

    (3)

    Fifty mSv yrl and age in 1Os of mSv appear reasonable forall licensees, both in terms of the

    lifetime risk of cancer and severe genetic effects to the most highly exposed workers, and the

    practicality of operation. In some segments of the industry, this acceptability is based on the

    adoption of a grandfather clause for those people exceeding or close to exceeding the cumula-

    tive limit at this time.

    Detailed nformation for fuel fabrication, waste management, manufacturing, well logging, and industrial

    radiography s sparse and such data would be useful for a full understanding of the potential impact of any

    reduction in the dose limits.

    iii

    NUREG/CR-6112

  • 8/11/2019 NRC-2009-0279-0038

    6/79

  • 8/11/2019 NRC-2009-0279-0038

    7/79

    Contents

    Page

    Abstract ............................................................................... iii

    Executive Summary

    ......................................................................

    v

    Foreword .............................................................................. xi

    Acknowledgments

    . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

    xii

    1 Introduction ......................................................................... 1

    2

    Historical Background and Literature Survey

    ............................................... 2

    2.1 1928to1977 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

    2.2 1977to1987

    . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

    2

    2.3 1987to 1994

    ..................................................................

    3

    2.4

    Background Summary

    ..........................................................

    5

    3

    DataGathering

    ......................................................................

    6

    3.1 Existing Surveys ............................................................... 6

    3.1.1

    1992

    Edison Electric Institute (EEI) Report on Dose Limits and Guidelines . . . . . . . . . . . . .

    6

    3.1.2 Departmentof Energy Report (DOE) on the Implications of the BElRV Report . . . . . . . . . . 6

    3.1.3 Nuclear Regulatory Commission (NRC) Radiation Exposure Information and Reporting

    System(RE1RS)

    ............................................................ 6

    3.1.4

    Environmental Protection Agency (EPA) Report on Occupational Exposure to Ionizing

    Radiation in the United States ................................................. 7

    3.2

    Survey Performed for this Report

    ..................................................

    7

    3.2.1

    Questionnaire Design

    ........................................................ 7

    3.2.1.1

    Options for Potential Dose Limits

    ........................................ 7

    3.2.1.2

    Impacts of Reduced Dose Limits

    ......................................... 7

    3.2.1.3 1989

    Dose Experience

    ................................................. 8

    3.2.2 Questionnaire Distribution .................................................... 8

    3.2.3

    Working Committee on the Impact

    of

    Reduced Dose Limits

    ......................... 8

    3.3 Comments Received to the Draft NUREG Report

    ....................................

    8

    4

    SurveyResults

    . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

    9

    4.1

    Edison Electric Institute (EEI) Report

    ............................................... 9

    4.1.1

    Administrative Control Levels

    .................................................. 9

    4.1.2 Annual Reported Doses for 1985and 1989 ...................................... 9

    4.1.3

    Cumulative Dose Administrative Guidelines

    ...................................... 9

    4.1.4

    Cumulative Reported Doses for

    1989

    ..........................................

    10

    4.1.5

    Projected Cumulative Doses for

    1994 .......................................... 10

    V NUREG/CR-6112

  • 8/11/2019 NRC-2009-0279-0038

    8/79

    Page

    4.1.6

    4.1.7

    Effects of Changing the Annual Dose Guidance ..................................

    10

    Effects of Establishing a Cumulative Dose Limit

    .................................. 11

    4.2

    Department of Energy (DOE) Report

    ............................................. 11

    4.2.1

    Costlmpact ...............................................................

    11

    4.2.2

    4.2.3

    4.2.4

    Annual Reported Doses.

    1978

    to 1988 .........................................

    12

    Lifetime Cumulative Exposure Limits ...........................................

    13

    Impact on Facility Operations .................................................

    13

    4.3

    Selected

    1990

    Data from NRC REIRS ............................................

    14

    4.4 Information Obtained from the 1984 EPA Report .................................... 18

    4.4.1

    4.4.2

    4.4.3

    Males ....................................................................

    18

    4.4.4 Females ................................................................. 19

    Male and Female Workers in the Nuclear Industry

    ................................ 18

    Correlation of Radiation Dose with Age

    ......................................... 18

    4.5 Responses to the Request for Comment

    ..........................................

    19

    4.5.1 Nuclear Power Reactor and Nuclear Power Reactor Contractors ..................... 19

    Organization of Licensees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19.5.1 I

    4.5.1.2 Three Separate Responses were Received from Three of the Nuclear Power Plant

    Sites

    .............................................................. 21

    4.5.2 Test and Measurement Including Industrial Radiography .......................... 22

    Manufacturing and Distribution Including Cyclotron Produced Radiopharmaceuticals

    .... 22

    Fuel Fabrication. UF, Production

    ..............................................

    22

    Questionnaire Results Obtained in this Survey

    ............................................ 23

    MedicaVDental and Veterinary Practice ............................................ 23

    5.2

    Nuclear Power Reactors .......................................................

    25

    Nuclear Power Reactor Contractors

    .............................................. 29

    Test and Measurements Including Industrial Radiography

    .............................

    31

    Manufacturing and Distribution. Including Cyclotron Produced Radiopharmaceuticals ......

    34

    5.7 WasteManagement . . . . . . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . . . . . . 36

    Fuel Fabrication. UF, Production

    ................................................. 37

    5.9 Well Logging

    .................................................................

    39

    Others (R&D. Regulatory) ......................................................

    40

    High Dose Groups Within an Industry

    ................................................... 41

    4.5.3

    4.5.4

    5

    5.1

    5.3

    5.4

    5.5

    Universities 33

    5.6

    5.8

    5.10

    . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

    6

    6.1 Introduction

    ..................................................................

    41

    6.2

    NRC-Sponsored Study on High Dose Group Workers

    ................................

    41

    6.2.1

    Analysis of Dose Data Obtained in the Study .................................... 44

    6.2.1.1

    6.2.1.2

    Pressurized Water Reactor Data ........................................

    44

    Boiling Water Reactor Data ............................................ 44

    NUREG/CR-6112

    vi

  • 8/11/2019 NRC-2009-0279-0038

    9/79

    Page

    6.2.1.3

    Contractor Data .....................................................

    44

    7 CostsAssociated With Dose Reduction Modificationsin the Nuclear Power industry .............. 46

    7.1

    Introduction ..................................................................

    46

    7.2

    Costs (and the Related Dose Saved) of Selected Modifications Which Might be Employedto

    ReduceExposure

    .............................................................

    46

    7.3 Estimated Impacts ............................................................ 51

    8

    Summary ..........................................................................

    55

    8.1 Medical/DentalNeterinary

    ......................................................

    55

    8.1.1 1RemYf ................................................................

    55

    8.1.2

    2RemYr ................................................................ 55

    8.1.3

    . . . . . . 55Rem Yrl and Cumulative Dose in Rem Less Than Age in Years Limit .......

    8.2

    Nuclear Power Reactor Plants and Their Contractors ................................

    55

    8.2.1 1

    Rem PerYP

    ............................................................ 55

    8.2.2 2

    RemYf

    ................................................................

    56

    8.2.3 5

    Rem Yf and Cumulative Dose in Rem Less Than Age in Years Limit

    ..............

    56

    8.3

    Test and Measurement Including Industrial Radiography. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

    57

    8.3.1 1

    RemYr

    ................................................................ 57

    8.3.2 2RemYr ................................................................ 57

    8.3.3

    5

    Rem Yr and Cumulative Dose in Rem Less Than Age in Years Limit . . . . . . . . . . . . . . 57

    8.4

    Universitiesnot Including Medical. Dental. or Veterinary Schools

    ....................... 57

    8.4.1 1

    Rem Yr Limit

    ........................................................... 57

    8.4.2 2

    Rem Yf Limit ...........................................................

    58

    8.4.3 5 Rem Yf and Cumulative Dose in Rem Less Than Age in Years Limit . . . . . . . . . . . . . . 58

    8.5 Manufacturing and Distribution Including Cyclotron-Produced Radiopharmaceuticals

    ......

    58

    8.5.1 1 Rem Yf Limit ........................................................... 58

    8.5.2 2

    Rem Yr Limit . . . . . . . . . . . .. . . . . . . . . . . . . .. . . . . . . . . . . . .. . . . . . . . . . . . . .. . . . . .

    58

    8.5.3

    5

    Rem Yr and Cumulative Dose in Rem Less Than Age in Years Limit

    .............. 58

    8.6

    Waste Management

    ........................................................... 58

    8.6.1 1

    Rem Yr Limit ...........................................................

    58

    8.6.2 2 Rem

    Yf

    Limit ...........................................................

    58

    8.6.3 5

    Rem Yf and Cumulative Dose in Rem Less Than Age in Years Limit ..............

    58

    8.7

    Fuel Fabrication. UF. Production

    .................................................

    58

    8.8

    Well Logging

    ................................................................. 59

    8.9

    Generai Conclusions ..........................................................

    59

    9

    References .........................................................................

    61

    Appendix

    A ............................................................................

    64

    vii

    NUREG/CR-6112

  • 8/11/2019 NRC-2009-0279-0038

    10/79

    Figures

    Page

    4.1

    4.2

    4.3

    4.4

    4.5

    4.6

    4.7

    4.8

    7.1

    7.2

    4.1

    4.2

    4.3

    4.4

    4.5

    4.6

    5.1

    5.2

    5.3

    5.4

    5.5

    5.6

    5.7

    5.8

    5.9

    5.10

    5.11

    5.12

    5.1 3

    5.14

    5.15

    5.16

    5.1 7

    5.1 8

    5.19

    5.20

    5.21

    5.22

    5.23

    5.24

    6.1

    6.2

    6.3

    6.4

    7.1

    Annual Site Doses for Utility Personnel (UT) and Total Plant Workers(TO) ................... 9

    Annual Site Doses for Utility Personnel (UT) and Total Plant Workers(TO) for 1985 and 1989 . . . 9

    Cumulative Sie Doses for Utility and Contractor Personnel for 1989

    .......................

    10

    Projected Cumulative Site Doses for 1994 Utility and Contractor Personnel

    . . . . . . . . . . . . . . . . .

    10

    Average Annual Dose Equivalent for DOE Workers with Measurable Exposure. 1978-1988 . . . . 12

    Number of

    DOE

    Employees

    ........................................................

    12

    Percent of Male Radiation Workers in Various Sectors .................................. 18

    Percent of Female Radiation Workers in Various Sectors ................................ 18

    Person-RemValues

    . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

    52

    Total Number of Reactors and Collective Dose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

    Tables

    Annual Exposure Data 1990 ....................................................... 15

    Annual Exposure Information for Industrial Radiographers* 1989

    ..........................

    16

    Annual Exposure Information for Fuel Fabricators* 1989................................. 16

    Annual Exposure Information for Manufacturers and Distributors 1989

    .....................

    16

    Summary of Annual Whole Body Distributions By Year and Reactor Type 1989

    . . . . . . . . . . . . . .

    17

    Mean Annual Dose Equivalent for U.S. Radiation Worker ................................ 19

    Impacts on MedicallDental and Veterinary Practice ..................................... 23

    1989ExposureExperience......................................................... 24

    Impacts in Nuclear Power Reactors

    . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

    25

    1989ExposureExperience

    .........................................................

    26

    1993 Exposure Experience (estimated)

    ..............................................

    26

    Impacts in Nuclear Power Reactor Contractors ........................................ 29

    1989Exposure Experience

    .........................................................

    30

    1993ExposureExperience......................................................... 30

    Impacts n Test and Measurements Including Industrial Radiography....................... 31

    1989ExposureExperience

    .........................................................

    32

    Impacts in Universities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

    Impacts in Manufacturing and Distribution

    .............................................

    34

    1993Exposure Experience

    .........................................................

    35

    Impacts n Waste Management ... ... ... ... .. ...................................... 36

    Impacts in Fuel Fabrication, UF, Production ........................................... 37

    1989ExposureExperience......................................................... 38

    1993 ExposureExperience......................................................... 32

    1989ExposureExperience. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

    1989Exposure Experience . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

    1989ExposureExperience

    .........................................................

    37

    Impacts in Well Logging ........................................................... 39

    1989ExposureExperience......................................................... 39

    Impacts n Others (R&D, Regulatory)

    .................................................

    40

    1989ExposureExperience

    .........................................................

    40

    Whole-Body Dose Data for PWR Plants for 1988

    .......................................

    41

    Whole-Body Dose Data for BWR Plants for 1988. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

    Whole-Body Dose Data for Various Worker Groups at PWR Plants for 1988

    . . . . . . . . . . . . . . . .

    43

    Whole-Body Dose Data for Various Worker Groups at BWR Plants for 1988 . . . . . . . . . . . . . . . . 43

    Estimated Costs and Dose Savings for Modifications at Nuclear Power Plants . . . . . . . . . . . . . . . 46

    NUREG/CR-6112

    viii

  • 8/11/2019 NRC-2009-0279-0038

    11/79

    Executive

    Summary

    The revised Nuclear Regulatory Commission (NRC) regulations 10 CFR

    20

    were based largely on the

    1977 recommendations of the International Commission on Radiation Protection (ICRP), as interpreted

    and promulgated by the Environmental Protection Agency (EPA) in 1987. Since then, the United Nations

    Scientific Committee on the Effects of Atomic Radiation (UNSCEAR), the National Research Council

    Committee on the Biological Effectsof Ionizing Radiation (BEIR), and the International Commission on

    Radiological Protection (ICRP) have published new information indicating that the risk associated with

    exposure to ionizing radiation

    is

    somewhat greater than that used by the ICRP and others in 1977. This

    increase reflects additional cancers found in the Japanese survivors of the atomic bombings, new

    dosimetry, and the adoption of a projection model which accounts for the excess cancer cases that are

    expected to occur in those survivors who are still alive.

    The ICRP recommended a dose limit of 100 mSv

    in

    5 years

    (1

    0 rem in five years) in its 1990

    recommendations. The National Council on Radiation Protection and Measurements (NCRP)in 1987

    recommended an annual limit of50mSv yr'

    (5

    rem yr') and suggested that no individual should exceed a

    cumulative dose equal to hidher age in 1

    Os

    of mSv (age in rem). This suggestion has been raised to the

    level of a recommendation in the 1993 Recommendations of the NCRP. Many countries in the world are

    drafting new regulations adopting the ICRP system.

    This study was requested by NRC to obtain a preliminary estimate of the potential impacts to NRC

    licensees of any reduction in the dose limits. In general, the past indepth reviews of the impact of

    lowering dose

    limits

    were based on an assumption that there would be no reductionin the source terms,

    no improvement

    in

    equipment (remote tooling and surveillance), nor any increase in the productivity of

    radiation workers.

    Four approaches were used in this study. The first was the development and distribution of a question-

    naire designed to solicit and evaluate information on the potential impacts of decreased dose limits from a

    wide variety of licensees. The second approach was the review and analysis of previous surveys on dose

    impacts and other data collections. These surveys were conducted by the Edison Electric Institute (EEI)

    Health Physics Committee, the Department of Energy (DOE), Office of Health and Safety, and the Brook-

    haven National Laboratory (BNL) ALARA Center. The data collections are those of the NRC Radiation

    Exposure Information Reporting System (REIRS) and Environmental Protection Agency (EPA) 1984

    Report on Occupational Exposure.

    The third approach was to use a working committee to validate and extend the data obtained from the

    questionnaire, and also review and comment on this report. This committee was composed

    of

    radiation

    protection experts from various sectors of NRC licensees, together with individuals from Nuclear

    Management and Resources Council (NUMARC), DOE, NRC, and the BNL ALARA Center. The fourth

    approach was to incorporate the comments made to the draft NUREG/CR-6112.

    Where possible, the data for 1989 was used as the basis for this report to allow meaningful intercom-

    parisons. The BNL High Dose Group Study was based on 1988 data, and the EPA Report was based on

    data of 1984 and earlier. Although the data for 1990 and 1993 suggests a reduction in individual and

    collective dose has taken place, the overall conclusions drawn from the 1989 study remain valid.

    Examplesof

    costs

    associated with reducing the source termin nuclear power plants were obtained from

    the NUREGER-4373, Compendium of Cost-Effectiveness Evaluations of Modifications for dose

    Reduction at Nuclear Power Plants, (Baum and Matthews, 1985).

    From the information given in this report and that offered by the working committee, several tentative

    conclusions can be drawn.

    ix

    NUREG/CR-6112

  • 8/11/2019 NRC-2009-0279-0038

    12/79

    The analysis suggests there would be minimal impact on collective doses, on costs of modifying facilities,

    or on annual radiation-protection costs under the combined limit of50 mSv yr' (5 rem yr') and cumulative

    dose in 1

    Os

    of mSv (rem) equal to age in years. The lifetime risk associated with thislimit - to an

    individual maximally exposed -would be slightly less than that incurred by a similar individual controlled by

    the ICRPs limit of 100 mSv in 5 years (10 rem in 5 years. However,

    a

    grandfather clause allowing up to

    20 mSv yf'

    (2

    rem y f

    )

    after exceeding the age limit will be required for perhaps less than 1000 workers.

    A 20

    mSv yrl (2 rem yr') limit would appear achievable, although some tasks, particularly those in

    medicine and in certain parts of the nuclear power industry, might prove extremely difficult o maintain.

    Extensive modifications, such as steam generation, maintenance, and refueling including the installation

    and use of robots and partialffullsystem decontamination, would be required for many tasks

    in

    nuclear

    power plants. Depending upon the extent of the modifications, the collective dose might go up or down.

    That is, extensive use of robots, source term reductions, and facility modifications might lower collective

    doses. Less ambitious modifications, less decontamination, and the use of fewer robots might keep the

    collective doses at about the same level while reducing individual doses; making no changes and allowing

    the same tasks to be performed would necessarily result in higher collective doses. The working

    committee suggested that with this annual limit, there could be a potential impact on safely since some

    discretionary inspection and maintenance might be constrained.

    For a 10 mSv yf' (1 rem yrl) limit, the risk to the most highly exposed individual would be lower than for

    other options, i.e. equivalent to that of fatal accidents in United States industries, but the impacts are

    expected to be quite serious for many of the industries which responded to the questionnaire. There are

    tasks, again in medicine, which under present procedures could be prohibitively expensive. For industries

    with large source terms, facility modifications and radiation protection costs would be extremely large (see

    Section7). For these reasons, collective dose may increase substantially.

    One additional issue must be kept in mind when assessing the impact of lower dose limits. That is, for

    licensees to ensure that doses do not exceed the regulated dose limits, they routinely use administrative

    limits. For example, with a regulatory limit of a50 mSv yr l

    (5

    rem yr'), an administrative limit of a

    40

    mSv

    yr' (4 rem yr') might be used. At

    20

    mSv y f '

    (2

    rem yr-') limit, a 15 mSvyf' (1.5 rem yf') administrative

    limit might be used, andso on.

    NUREG/CR-6112

    X

  • 8/11/2019 NRC-2009-0279-0038

    13/79

    Foreword

    On May 21,1991, the Nuclear Regulatory Commission (NRC) published a revision to 10 CFR Part

    20,

    Standards for Protection Against Radiation. The rule went into effect in June 1991, and all licensees

    were required to implement the regulations on or before January 1,1994.

    The revised 10 CFR Part 20 is based on the recommendations of the International Commission on

    Radiological Protection (ICRP) in Publication

    26

    (ICRP 1977). In 1991, ICRP published revised recom-

    mendations in Publication

    60.

    These recommendations were based upon revised dosimetry and

    epidemiology, including the information presented in reports such as the 1988 United Nations Scientific

    Committee on the Effects of Atomic Radiation (UNSCEAR). In this revision, ICRP reduced its recom-

    mended dose limit to 100 mSv (1 0 rem) in

    5

    years, with the additional limitation that no more than50 mSv

    (5

    rem) is received in any one year.

    In 1991, the National Council on Radiation Protection and Measurements (NCRP) recommended a lifetime

    limit of 10 mSv

    (1

    rem) times age in years (NCRP 91). NCRP is currently reexamining

    its

    recommenda-

    tions based on ICRP60.

    As

    a result of these recommendations, n 1988, the NRC staff initiated a study by Brookhaven National

    Laboratory to analyze the potential impacts of reduced dose limits on its licensees and to provide a

    technical base upon which to base future regulatory decisions. This NUREG summarizes the results of

    that study, which included a survey of radiation protection experts. Even though the information presented

    is not complete for certain categories

    of

    licensees due to unavailability, the conclusions for those where

    data was available are considered valid.

    Inview of the small number of licensees who responded to the survey, the NRC staff decided to publish a

    draft of this report for public comment in the hopes that additional data and expert opinion would result,so

    that a more extensive technical base could be developed. Licensees, agreement states, and all other

    interested parties were encouraged to submit comments and relevant data on this draft report.

    This NUREG incorporates the information from the comments received.

    NUREGER-6112

    is

    not a substitute for NRC regulations, and compliance is not required. The a p

    proaches and/or methods described in this NUREG/CR are provided for information only. Publication of

    the report does not necessarily constitute NRC approval or agreement with the information cited therein.

    YK

    ~ e G ~ ~ ~ - -

    Radiation Protection

    &

    Health Effects Branch

    Division of Regulatory Applications

    Office of Nuclear Regulatory Research

    xi

    NUREGER-6112

  • 8/11/2019 NRC-2009-0279-0038

    14/79

    Acknowledg men&

    This report is the result of efforts of many individuals. In addition to the author, the staff of the Brookhaven

    National Laboratory (BNL)

    A U R A

    Center, John Baum, Tasneem Khan, Bruce Dionne, and Casper Sun

    made major contributions to the report.

    The working committee of Larry Brennecke, Thomas McLeod, Thomas Gaines, George OBannion,

    Howard Elson, Frank Rescek, Frank Roddy, Robert Robinson, Alan Roecklein, Anthony Weadock, George

    Powers, Ralph Andersen, Jay Maisler, Tasneem Khan, and Bruce Dionne provided data, insightful com-

    ments and suggestions, and helpful editorial suggestions.

    Alan Roecklein and the Project Manager, George Powers, gave us the necessary oversight, advice, and

    support required to complete this phase of the work.

    Finally, the patience and precision of Karen Wagner in preparing and editing the report is gratefully

    acknowledged.

    NUREG/CR-6112 xii

  • 8/11/2019 NRC-2009-0279-0038

    15/79

    Impact

    of

    Reduced Dose Limits

    on NRC Licensed Activities

    1 Introduction

    The revised Nuclear Regulatory Commission (NRC)

    regulations, 10 CFR

    20,

    (NRC, 1991) impose an an-

    nual effective dose equivalent limit of

    50

    mSv

    (5

    rem)

    on occupationally exposed workers. This requirement

    corresponds to that given in the Environmental Pro-

    tection Agency's (EPA's) 1987 Radiation Protection

    Guidance for Occupational Exposure-Recommen-

    dations (EPA, 1987) approved by the President. Both

    of these agencies based their requirements largely on

    the 1977 recommendations of the International

    Commission on Radiological Protection (ICRP) given

    in their Publication 26 (ICRP, 1977).

    In

    the

    late 1980s, the Radiation Effects Research

    Foundation (RERF) updated the data on their life-

    span study of the Japanese atomic bomb survivors to

    account for the increase in cancer incidence as a

    function of dose associated with a revision in the

    dosimetry (Shimizu et al., 1987; 1988). Another in-

    crease in the risk factors resulted from a potential

    increase in the risk associated

    with

    further epidemio-

    logical support for the multiplicative or relative risk

    projection model. The National Council on Radiation

    Protection and Measurements (NCRP) modified their

    basic recommendations to reflect this preliminary data

    in 1987 (NCRP, 1987). The NCRP also noted the

    substantial decrease

    in

    the frequency of fatal indus-

    trial accidents that had been the basis for the risk-

    based dose limit given by ICRP

    in

    1977. This fre-

    quency decreased from about 1

    x

    1

    4

    yf ' in the early

    1970s to about

    4

    x 10'5 n the mid 1980s.

    Shortly thereafter, the United Nations Scientific Com-

    mittee on the Effects

    of

    Atomic Radiation (UNSCEAR)

    and the National Research Council Committee on the

    Biological Effects of Ionizing Radiation (BEIR) pro-

    duced the 1988 UNSCEAR Report (UNSCEAR, 1988)

    and the 1990 BEIRV Report, (NASBEIR, 1990) re-

    spectively.

    1

    4

    rem-') for adults, and about

    5 x

    1

    O-2Sv'

    5

    x

    10-4

    rem ) for the total population (ICRP, 1991). Although

    the ICRP has changed

    its

    criteria for selecting dose

    limits, this increased estimate of the risk of fatal can-

    cer alone from 1.25

    to 4 x

    1

    0-' Sv'

    1.25

    to

    4

    x 1

    O4

    rem-') given in ICRP Publication 26 (ICRP, 1977)

    suggested that an annual limit of50 mSv

    (5.0

    rem)

    over a working lifetime was unlikely to be considered

    acceptable. Their solution, given in Pubiication60,

    was to recommend an occupational limit of 100 mSv

    in 5 years (20 mSv yrl )

    [I

    em in 5 years (2 rem yr')]

    with

    an additional limit of50mSv (5 rem) in any year.

    The International Atomic Energy Agency

    (IAEA)

    and

    the Commission of European Communities (CEC)

    already have begun to revise their basic safety stan-

    dards to conform with ICRP's new recommendations.

    In light of these developments, in 1988 the NRC re-

    quested that a preliminary study be madeto analyze

    the potential impacts of reduced dose limits on its

    licensees, and to provide a technical base for making

    future regulatory decisions on limits. This report sum-

    marizes the results of a review on the impact of re-

    duced dose limits o NRC licensees.

    Using the preliminary information from the 1988

    UNSCEAR report, the ICRP began a major revision to

    its

    recommendations, beginning

    with

    a detailed review

    of the data. The revised estimate of the lifetime fatal

    cancer risk for low dose or low dose-rate exposure

    given in ICRP Publication 60is -4 x 10-' Sv' (-

    4

    x

    1 NUREG/CR-6112

  • 8/11/2019 NRC-2009-0279-0038

    16/79

    2.1 1928 to 1977

    The first widely accepted dose-limiting recommen-

    dations were based on keeping exposures below the

    threshold for observable effects (Mutscheller, 1925).

    By the end of the second world war, theselimits,

    which by then reflected concern over leukemia and

    genetic effects, were expressed as

    300

    mremheek to

    tissues at a depth of

    5

    cm

    or

    more in the body, and

    600

    mreml week to the surface of the body (NBS,

    1954; ICRP, 1954). These values were equivalent to

    the later limits of 15 rem yr' to most of the individual

    organs with the exception of the blood-formingtis-

    sues, the gonads, and the lens of the eye (NCRP,

    1971; ICRP, 1959a), and 30 rem yr' to the skin (NRC,

    1960; ICRP, 1964).

    After the second world war, there was much public

    concern over world-wide fallout from nuclear tests

    (Divine, 1978). Mueller and others were convinced

    that for genetic effects at least, there was a linear no-

    threshold response (Mueller, 1927; Lea, 1947). The

    National Academy of Sciences-National Research

    Council (NAS-NRC, 1956) and the Briish Medical

    Research Council (MRC, UK, 1956) formed expert

    committees to examine the radiobiological evidence.

    The basic consideration was the need to restrict the

    genetic damage to both exposed individuals and to

    the general population. Based heavily on the dose-

    effect relationship for genetic effects seen in Drosoph-

    -

    la and on the observed genetic burden seen in hu-

    mans, assumed to be partly due to the natural radia-

    tion background (Haldane, 1948), the next set of limits

    reflected:

    1)

    a need to limit cumulative dose, and 2) a

    need to restrict the cumulative dose to workers in their

    reproductive years below that for older workers. The

    resulting limits for whole-body penetrating radiation

    were (age

    -

    18) 5 rem cumulative dose and3 rem/

    quarter (NCRP, 1957; ICRP, 1959b).

    By the early 60s, the data from the Japanese survi-

    vors of the atomic bombs began to emerge (UNS-

    CEAR, 1962). This data, together with that from the

    early radiologists and British spondylitic patients,

    suggested that the incidence of leukemia increased

    as a result of radiation.

    A decade later,

    it

    was apparent that the incidence of

    certain solid tumors also increased in the Japanese

    survivors, the British spondylitic patients, and women

    with mastitis who had been treated

    with

    X rays

    (UNSCEAR, 1972; BEIR, 1972).

    Consequently, he InternationalCommission on

    Radiological Protection (ICRP), the National Council

    on Radiation Protection and Measurements (NCRP),

    and the Federal Radiation Council (FRC) all re-

    emphasized the need to keep exposure as low as

    practical, practicable, or reasonably achievable.

    2.2 1977

    to

    1987

    In the middle 70s, the United Nations Scientific Com-

    mittee on the Effects of Atomic Radiation (UNSCEAR,

    1977) felt there was sufficient nformation rom the

    Japanese atomic bomb survivors to estimate the risks

    to individual organs. This led to the adoption by the

    ICRP in 1977 of the effective dose equivalent con-

    cept', with

    its

    attendant w values (weighting factors

    representing he proportion of the stochastic risk from

    individual issues relative to the risk to the whole body

    when the body is irradiated uniformly). In addition, the

    ICRP justified the 50mSv yfl (5 rem yr') limit on the

    basis that the average dose would be less than 10

    mSv yr'(1 rem yrl) and, as UNSCEAR had done, as-

    sumed that the risk from low dose, low dose-rate

    exposure was

    2.5

    times less than that seen in Japa-

    nese atomic bomb survivors. The first of these two

    criteria led ICRP in 1977 to eliminate the (age

    -

    18)

    5

    rem recommendation.

    Perhaps the greatest significance of the 1977 ICRP

    Publication 26 was the development of the close rela-

    tionship between risk and dose limits. Simply put, an

    average excess risk of fatal cancer and severe ge-

    netic effects of

    l

    I O - *

    Sv'

    (1x

    l 4

    rem-') was judged

    to be acceptable by the ICRP.

    At the time that ICRP published their recommended

    occupational limito f 50 mSv yrl (5 rem yf ) (ICRP,

    1977), several different sets of limits were being

    recommended or used in the United States.

    '

    The concept originated in ICRP Publication 26 (ICRP, 1977)

    although the term effectivedose equivalent was not intro-

    duced until 1978 (statement from the 1978 StockholmMeeting

    of the ICRP Annals of the ICRP,

    Vol.

    2, No.

    1.

    (1978).

    NUREG/CR-6112 2

  • 8/11/2019 NRC-2009-0279-0038

    17/79

    The NCRPwas recommending a limit of

    5

    rem yf'

    and (age - 18)5 rem (NCRP, 1987); the Federal Radi-

    ation Council (FRC) was recommending rem/quarter

    and (age-18)

    5

    rem (FRC, 1960); both the Nuclear

    Regulatory Commission (NRC) and the Occupational

    Safety and Health Administration (OSHA) were en-

    forcing 3 remlquarter and (age-18) 5 rem, and the

    Department of Energy (DOE) were enforcing rem/

    quarter and5 rem yr'. During this period, the Natural

    Resources Defense Council (NRDC) petitioned both

    the EPA and the NRC to lower occupational exposure

    limits in the United States. The federal agencies'

    response to the petition eventually led to several re-

    ports on the impact of lowering the Annual Dose

    Equivalent limit from

    5

    rem to

    0.5

    rem.

    The earliest report was prepared or Stone and Web-

    ster Engineering Corporation by Warman et al., 1978.

    Their basic conclusion was that a decrease in the

    dose limit to about2 em yrl would exponentially

    increase both collective dose and the number of addi-

    tional workers needed. Below2 em yrl, the increase

    per unit dose reduction would be even greater. These

    results were based on the dose distribution of Pres

    surized Water Reactor (PWR) and Boiling Water Re-

    actor (BWR) workers in 1976. The basic assumptions

    were that the dose received by workers that was

    above any new dose limit would have to be received

    by additional workers, and that the dose rates existing

    at the power plants at that time would be represen-

    tative of future dose rates. All workers were assumed

    to be productive 90% of the time.

    A more detailed analysis was made by the Atomic

    Industrial Forum (AIF) a few years later in which the

    impacts were analyzed by tasks (AIF, 1978). The

    overall conclusion, taken from a statement in the

    report, was While exposure and costs do increase,

    manpoweris considered the most significant con-

    cem. Again, it is important to recognize that AIF

    assumed

    (1)

    that there

    will

    be no significant design

    improvements made leading to the reduction of expo-

    sure or to improved operation or maintenance , and

    (2) that work in a radiation environment at commer-

    cial nuclear power plants

    will

    not be performed signifi-

    cantly differently at lowered exposure limits than it is

    at present limits.

    The DOE conducted a similar study for their facilities

    (DOE, 1979). Rather than employ the models used in

    the AIF study, DOE relied on a detailed questionnaire

    and a review committee. However, their conclusions

    3

    Historical Background

    were no different than those

    of

    the two reportsde

    cussed above, except that the impacts occurred at

    slightly lower doses because DOE was then using a

    5

    rem yrl limit. The DOE report recommended that the

    concept of As Low As Reasonably Achievable

    (ALARA) should have greater attention than a reduc-

    tion in dose limit. Also, there was more emphasis on

    potential facility modifications and reduction of source

    terms.

    Fortunately, since these reports were issued, extraor-

    dinary strides in reducing exposure using the

    ALARA

    principle and restrictive administrative imits have

    significantly reduced collective dose without increas-

    ing the average annual dose to workers. In fact, the

    combination of improvements in productivity, design,

    and source-term reduction has decreased the average

    individual dose at both NRC licensees and DOE facili-

    ties over the past decade. This was most clearly

    demonstrated in the Naval Nuclear Propulsion Pro-

    gram (Schmitt and Brice, 1984), and in the commer-

    cial nuclear power industry (Brooks, 1988).

    2.3 1987 to 1994

    Today, the weight of new radiobiologicalevidence on

    dose limits is as important as it was in the early

    1950s. The incorporation of (age

    -1

    8)

    5

    rem into the

    recommendations and limits at that time was ac-

    cepted with l i l e difficulty (except, perhaps, in uranium

    mining and fuel fabrication). The most recent evi-

    dence from the Japanese

    survivors,

    reviewed by

    UNSCEAR (UNSCEAR, 1988) and the National Aca-

    demy of Sciences (NAS) Committee on the Biological

    Effects of Ionizing Radiation (BEIR, 1990), suggests

    that the risks of fatal cancer and severe genetic ef-

    fects may be up to

    4

    times greater than those esti-

    mated in 1977.

    Reacting to the emerging information from the Rad-

    ation Effects Research Foundation (RERF) in Japan

    (Preston and Pierce, 1981), the ICRP .ssued a state-

    ment in 1987 following

    its

    meeting in Como, Italy

    (ICRP, 1987). The Commission suggested that:

    (1)

    revised dosimetry could increase the cancer

    risklunit dose by a factor of 1.4, (2) the observed

    increase in the incidence of solid tumors in younger

    members of the exposed population might lead to a

    combined increase of a factor of2, and (3) the rela-

    tive risk projection model could increase the risk factor

    even further. The Commission also noted that a new

    NUREG/CR-6112

  • 8/11/2019 NRC-2009-0279-0038

    18/79

    Historical Background

    set of basic recommendationswould beavailable in

    1990.

    Mostworkers seem to have been adequately pro-

    tected under the (age

    -

    18)

    5

    rem dose limit. The

    average annual exposure to monitored workers with

    measurable exposure was about 230 mrem (EPA,

    1984). Using the 1990 ICRP risk estimates of 5

    X 1

    -*

    SV'

    -4

    x

    1

    O4

    rem-') for fatal cancer for those aged

    18-65, the lifetime of fatal cancer risk to an individual

    receiving he annual exposure of 2.3 mSv (230 mrem)

    is predicted to be

    -1

    x

    1

    4. This figure is comparable

    to the risk of accidental death in U.S. industry.

    However, for a worker receiving 50 mSv

    (5

    rem) in

    one year, these same risk estimates project a lifetime

    risk of attributable fatal cancer and severe genetic

    effects

    at

    2.5

    x

    1

    03.

    Such an annual level of risk is

    compar-able to that associated with the upper range

    of risk in mining, construction, and agriculture, includ-

    ing deep-sea fishing. For those few workers who may

    receive annual doses near the dose limit over much of

    their working lives, the cumulative level of risk may be

    unacceptable.

    Consequently, the National Radiation Protection

    Board (NRPB)

    in

    England ssued interim guidance in

    November 1987 (NRPB, 1987) in which they recom-

    mended that

    ...

    occupational workers exposure

    should be

    so

    controlled as not to exceed an average

    effective dose equivalent of 15 mSv yr'.*'

    This NRPB Guidance is, in fact, quite similar to the

    1987 recommendation of the NCRP in

    its

    Report 91

    (NCRP, 1987)

    in

    which the Council stated ...the com-

    munity of radiation users is encouraged to control their

    operations in the workplace in such a manner as to

    ensure, in effect, that the numerical valueof the indi-

    vidual worker's lifetime effective dose equivalent n

    tens

    of

    mSv (rem) does not exceed the value of his or

    her age in years. Both approaches would lead to

    lifetime doses below 750 mSv (75 rem).

    Both guidances reflected an expectation that risk

    estimates would increase and safe industries would

    continue to become safer.

    In general agreement with other countries, the Federal

    Republic of Germany stated that before changing

    annual dose limits

    it

    will await completion of interna-

    tional discussion following the issuance of the 1990

    ICRP recommendations. However, the German au-

    thorities made a rather dramatic change in their rec-

    ommendations (Kaul et al., 1989):

    Under the present conditions, the German

    Commission on Radiological Protection

    (SSK)

    recommends hat the rule of minimization be

    applied more strictly and that in the future, in

    adherence to the annual dose limit of the

    Radiological Protection Ordinance of

    50

    mSv,

    a total dose of400 mSv during a whole work-

    ing lifetime shall not be exceeded (occupa-

    tional lifetime dose).

    A

    comprehensive report on the impacts of dose-limit

    reduction was produced n 1988 for the Electrical

    Power Research Institute (EPRI) (Le Surf, 1988). The

    author suggested that although there have been sig-

    nificant reductions n both individual and collective

    doses in the U.S. nuclear power industry, basic and

    fundamental changes are needed

    if

    this industry is to

    comply with lower limits. He points out that other

    countries have successfully reduced exposure in

    three ways: first, by changing the philosophy of radia-

    tion protection, emphasizing line responsibility and

    training; second, by introducing aggressive measures

    to reduce the source term; and third, by incorporating

    similar approaches to prevent the buildup of radiation

    fields. The NRC established an AIARA Center at

    Brookhaven National Laboratory (BNL), which main-

    tains a database for these issues (Khan et at., 1992;

    Baum and Khan, 1992; Khan et al., 1991b).

    In January 1991, the ICRP issuedits Publication 60,

    The 1990 Recommendations of the International

    Commission on Radiological Protection (ICRP, 1991)

    recommending a limit

    of

    100 mSv in

    5

    years, with the

    caveat that no more than

    50

    mSv be allowed in any

    one year. The Commission's intention was to limit the

    lifetime effective dose to

    -

    1 Sv

    (100

    rem) and the

    average annual effective dose equivalent to 20 mSv

    (2 rem).

    The most recent NCRP recommendationsgiven in its

    Report 116, Limitation of Exposure o Ionizing Radia-

    tion, raise the guidance given in NCRP Report 91

    ,

    Recommendation on Limits for Exposure to Ionizing

    Radiation, on a lifetime dose in 1

    Os

    of mSv equal to

    age in years (lifetime dose in rem equal to age in

    years) to the level of a recommendation. The NCRP

    Report 116 also maintains the recommendation of

    50

    mSv yr'

    (5

    rem yr').

    NUREG/CR-6112

    4

  • 8/11/2019 NRC-2009-0279-0038

    19/79

    Historical Background

    It

    is importand o know that UNSCEAR reaffirmed he

    ICRP risk estimate in both their 1993 (UNSCEAR,

    1993) and 1994 (UNSCEAR, 1994) reports.

    The

    MEA

    has revised of the Basic Safety Standards

    as has the CEC. The European Community

    is

    ex-

    pected to have a new set of requirements based on

    ICRP

    60

    in place by the middle of this decade, with

    many other nations following soon after.

    2.4 Background

    Summary

    In general, past in-depth reviews of the impact of

    lowering dose limits were based on an assumption

    that there would

    be

    no reduction in the source terms,

    no improvementinequipment (remote tooling and

    surveillance), nor any increase in the productivityof

    radiation workers. However, reductions n dose limits

    led to the realization hat all of these assumptions

    may be incorrect.

    It

    is essential that any review of the

    impact of lowering dose limits addresses the financial

    impact of lowering collective doses, not simply the

    redistribution of existing exposure.

    5

    NUREG/CR-6112

  • 8/11/2019 NRC-2009-0279-0038

    20/79

    3 Data Gathering

    In

    this study we proposed to use existing surveys and

    to obtain opinions on the impacts of reductions in the

    dose limit from as broad a spectrum of users as possi-

    ble without resorting to an intensive site-by-site as-

    sessment.

    In

    addition to reviewing such surveys,

    such as the EEI, the DOE, and recent NRC-spon-

    sored studies on dose reduction, therewas a wide-

    spread distribution of a questionnaire to elicit the

    responders' opinion and to obtain specific data to

    assist in our overall assessment of the impact. Data

    from the NRC's Radiation Exposure Information and

    Reporting Sysfem (REIRS) and the 1984 EPA Report

    on Occupational Exposure were used to validate the

    survey data. In addition, data and information su p

    plied in the comments received on the draft

    NUREGER-6112

    will

    be reviewed.

    3.1

    Existing

    Surveys

    3.1 I 1992 Edison Electric Institute (EEI)

    Report on Dose Limits and Guide-

    lines

    Questionnaires were sent to all members of the

    EEI

    Health Physics Committee addressing the following

    topics:

    1)

    current practices and experience on ad-

    ministrative dose-control levels, 2) cumulative dose

    guidelines and experience,3) projected mpacts asso-

    ciated with lifetime dose limits, and 4) effects of a

    reduced annual dose limit and of establishing a cumu-

    lative dose limit. Twenty-seven individuals replied,

    representing 23 nuclear utilities. These responses

    covered 43 Pressurized Water Reactors, 18 Boiling

    Water Reactors, and a High Temperature Gas Cooled

    Reactor, encompassing more than half the nuclear

    power plants (62 out of 108 units in 1989). They

    obtained dose data for> 14,500 and> 12,500 individ-

    uals with doses

    > 500

    mrem in 1985 and 1989,

    respectively. For these two years, the number of

    personnel at U.

    S.

    ower reactors with doses

    > 500

    mrem was about 27,000 and 25,000, respectively.

    The responses were stored in a computer database

    and published as graphs and tables, with the authors

    of the report using their best udgment to interpret the

    utilities' responses. The full survey is reported n the

    EEI Nuclear Report, Utility Response to Question-

    naire on Dose Limits (EEI, 1991); Section 4.1 gives a

    brief summary.

    NUREGER-6112

    6

    3.1.2

    Department of Energy Report

    (DOE) on the Implications of the

    BElRV Report

    In response to a request by the Secretary of Energy,

    the Office of Health reviewed the implications of the

    BElRV report for the Department of Energy (DOE).

    A

    questionnaire was developed by a DOE internalRe-

    view Committee to survey DOE contractors to esti-

    mate costs for additional personnel, programmaticup-

    grades, and engineering modifications that would

    be

    needed to comply

    with

    an anticipated reduction n the

    dose limits.

    The questionnaire was sent to the Albuquerque, Chi-

    cago, Idaho, Nevada, Oak Ridge, Richland, San Fran-

    cisco, and Savannah River Field Offices on January

    30, 1990, for distribution to their contractors. Thirty-

    seven contractor sites responded, which operate the

    following types of nuclear facilities: accelerators,

    fuelhranium enrichment, fuel fabrication, fuel

    processing, maintenance and support, hot cells, reac-

    tors (test, research, and production types), research

    and development, fusion, waste processing/storage,

    weapons fabrication and testing, tritium production,

    and radiography. Two significant contributors to

    DOES collective dose, the Rocky Flats plant in

    Golden, Colorado, and

    Los

    Alamos National Labo-

    ratory in

    Los

    Alamos, New Mexico did not respond.

    The scope and findings of the survey are given

    in

    the

    Final Report to the Secretary of Energy; Implication

    of the BElR

    V

    Report to the Department of Energy

    (DOE,

    1990). The results are summarized in Section

    4.2 of this report.

    3.1.3 Nuclear Regulatory Commission

    (NRC)

    Radiation Exposure Infor-

    mation and Reporting System

    (REIRS)

    The NRC established a radiation exposure informa-

    tion and reporting system (REIRS) and publishes data

    from

    six

    of the seven categories of NRC licensees

    subject to the reporting requirementsof 10 CFR

    20.407. Selected data from NUREG 0713

    Vol

    12

    (Raddatz and Hagemeyer, 1993), which presents data

    for 1990, are given in Section 4.3 of this report; it

    serves as one elementof the processof ensuring that

    the survey responses provide a realistic picture of the

  • 8/11/2019 NRC-2009-0279-0038

    21/79

    exposure statistics. Itshould be noted that the REIRS

    data contains information from NRC licensees only.

    Companies that are licensed by agreement states do

    not report their exposures to the NRC, so the data for

    industrial radiography, manufacturing, and distribution

    of specified quantities of by-products and low-level

    waste do not reflect the total United States exposure.

    3.1.4 Environmental Protection Agency

    (EPA) Report on Occupational Ex-

    posure to Ionizing Radiation in the

    United States

    Because the U.

    S.

    nuclear industry is spread over

    many diverse sectors,

    it

    is very difficult to get a com-

    plete, comprehensive picture of the radiation expo-

    sure of all radiation workers. Fortunately, the Environ-

    mental Protection Agency (EPA) made a study which

    covers almost every sector (EPA, 1984). We ana-

    lyzed their data to gain detailed information for one

    year over the entire U.

    S.

    nuclear industry. Although

    the study is several years old, it is by far the most

    detailed of its kind and its main conclusions are useful

    to the current effort. Section 4 presents our analysis.

    3.2 Survey Performed for this

    Report

    A questionnaire designed to elicit response from

    a

    wide variety of radiation users was developed

    (Appendbc A).

    A working group of technical experts (see

    3.2.3)

    e-

    viewed the data from the questionnaire and obtained

    additional data where needed.

    3.2.1 Questionnaire Design

    Three classes of information were judged to be impor-

    tant: The responders' estimate of

    the

    impact as a

    function of several dose limiting options; their organ-

    ization's preliminary data on exposures; and lastly,

    their comments and suggestions. The questionnaire

    also solicited information about the respondent's

    organization and asked if the respondee could be-

    come a member of a working group to review and

    assess the results of the questionnaire.

    7

    Data Gathering

    3.2.1 I

    Options

    for

    Potential

    Dose

    Limits

    Four dose-limit options were proposed, each reflect-

    ing a rational response to the new risk estimates. The

    first

    option considered was 2 rem yf', which was the

    basic recommendation in the widely circulated drafl of

    the ICRP revision to its Publication 26 (the final rec-

    ommendation was

    100

    mSv in five years, and less

    than

    50

    mSv in any one year).

    The second option was

    1

    rem yfl, based on the

    UNSCEAR 1988 risk estimate being about 4 times the

    UNSCEAR 1977 risk estimate. Therefore,

    it

    might be

    prudent to reduce the

    5

    rem yr ' limit to about

    1

    rem

    yrl to account for this difference. In addition, the age-

    related approach suggested in NCRP91 could result

    in 1 rem yf ' if

    the

    regulatory agency is concerned

    about the record-keeping of cumulative dose limits.

    Furthermore, perhaps this isthe lowest level that

    could be imposed and

    still

    permit widespread use of

    radiation and radioactive materials.

    The third

    option

    was age in rem and

    5

    rem yf', which

    simply escalates the guidance given in NCRP Re-

    port 91 to a regulatory limit. Itallows up to 5 rem yf'

    which permits the continued operation of previously

    designed facilities without significant modifications,

    but ensures that the lifetime risk to any individual

    will

    be less than 100 rem.

    Fourth, a limit of age in rem and2 rem yrl was given

    because a regulatory agency may wantto regulatethe

    rate of exposure more closely than option3. In addi-

    tion, this limit option appears

    to

    be closer

    to

    the

    ICRPs recommended limit of

    100

    mSv in five years,

    and has the advantage of restricting exposure in the

    early years of working life more than does option

    3.

    These four options are not intended as suggestions

    for new regulatory limits, but merely as the most prob-

    able ones which a regulator might consider.

    3.2.1.2

    Impacts

    of

    Reduced

    DoseLimits

    Previous studies on the impacts of reduced dose

    limits usually cite increased costs and increased col-

    lective dose. The questionnaire asked that costs be

    broken down between those required for modifying

    the facility, and operating costs. The first are

    expected to

    be

    one-time costs, and the latter recurring

    costs.

    NUREGER-6112

  • 8/11/2019 NRC-2009-0279-0038

    22/79

    Data Gathering

    3.2.1.3

    1989 Dose Experience

    To allow BNL to make a less subjective assessment,

    six

    items of related data were requested. The first

    three were the number of employees

    with

    exposure in

    excess of

    5

    rem,

    2

    rem, and

    1

    rem in 1989, data

    clearly related to the potential limits given in the

    o p

    tions. The fourth item was a request for information

    on the number of employees whose current lifetime

    dose in rem exceeds their age, which would highlight

    any need for grandfathering . The number of

    employees with measurable dose was requested to

    judge the weight that should be given to the specific

    data in the questionnaire. The annual collective dose

    also was requested, which, when taken with the

    above data, could provide information on the dose

    distribution, and assist in evaluating the answets

    about the impact on collective dose.

    3.2.2 Questionnaire Distribution

    The questionnaire and an explanation ofits intended

    use was published in the July 1990 issue of the

    Health Physics Society Newsletter, which is distrib-

    uted to the nearly 6,000 members of the society. The

    societyis composed of scientists, engineers, and

    professionals concerned with radiation protection

    throughout the United States,so

    it

    was felt that virtu-

    ally all categories of radiation users would have ac-

    cess to

    it.

    A letter describing the questionnaire andits

    availability was published in the newsletter of the

    American Association of Physicists in Medicine. The

    majorityof Medical physicists and medical health

    physicists belong to this society,

    so

    this category of

    radiation users was given a unique opportunity to

    participate.

    3.2.3 Working Committee on the Impact

    of Reduced Dose Limits

    From the inception of this study, we recognized that

    the questionnaire alone could not ensure that all occu-

    pational exposure practices were adequately asses-

    sed. In addition, the questionnaire might elicit subjec-

    tive information which, while helpful, could lead to

    misinterpretation of the actual impact, particularly

    where there were few responses from a particular

    industry or practice. Therefore,

    a

    working committee

    was assembled composed of individuals with experi-

    ence and knowledge in radiation protection from a

    wide variety of industries and practices. The member-

    ship included: from medical activities (Larry

    Brennecke and Thomas McLeod); from industrial

    NUREG/CR-6112

    8

    radiography (Thomas M. Gaines); from well logging

    (George O'Bannion); from the university community

    (Howard K. Elson); from nuclear power plants (Frank

    Rescek); from nuclear plant contractors (Frank

    Roddy); from fuel fabricators (Robert Robinson); from

    NUMARC (Ralph Andersen and Jay Maisler); from the

    Nuclear Regulatory Commission (George Powers and

    Alan Roecklein); and from the Department of Energy

    (Anthony Weadock). Bruce Dionne and Tasneem

    Khan of the BNL AURA Center also participated.

    The working committee met on March 27,1991 to

    review the data from the questionnaires. They also

    reviewed the study by the DOE on the implications

    of

    BElR V to the DOE, and the BNL ALARA Center

    study on highdose worker groups at nuclear plants

    (both are discussed elsewhere in this report). Addi-

    tional data was received from the participants during

    the meeting, and areas requiring more information

    were identified.

    After this meeting, questionnaires were mailed to

    additional radiographers, fuel-fabrication workers, and

    nuclear-plant contractors.

    A

    letter in the October 1991 ssue of the Health Phys-

    ics Society Newsletter summarized the information

    from the responses received up to that point. This

    letter specifically requested comments and sugges-

    tions. Because there were no responses, a follow-up

    letter was published in the March 1992 ssue. Only

    two responses were received by the endof May.

    A second meeting of the working group was held in

    July 1992 when several specific comments and sug-

    gestions were made (see Chapter

    5).

    3.3 Comments Received

    to

    the

    Draft NUREG Report

    The NUREG/CR-6112 Draft Report was distributed for

    public comment in early 1994. Seven sets of com-

    ments were received. This additional information

    included comments and data from the nuclear power

    plant community, the fuel fabrication community, the

    radio-pharmaceutical production community, and the

    industrial radiography community. The comments

    have been addressed in Section4.5, and much of the

    data and detailed comments are included in Section

    5.

  • 8/11/2019 NRC-2009-0279-0038

    23/79

    4.1

    4 Survey Results

    Edison E lectric Institute (EEI)

    Report

    I

    m

    4.1

    I

    Administrative Control Levels

    In the EEI Report

    (EEI, 1991)

    twenty-seven people

    reported administrative control levels:six use a

    5

    rem

    annual limit ; eight have adopted a

    4.5

    to

    4.9

    rem yr'

    value; eleven use an annual control level of approxi-

    mately

    4

    rem yr ' (which was the guideline published

    by the Institute of Nuclear Power Operations (INPO)

    in

    1988);

    and

    two

    have adopted progressive levels of

    2.5 rem yr'.

    4.1.2 Annual Reported Doses for 1985

    and 1989

    Figure

    4.1

    (taken from the

    EEI

    Report) shows the

    number of workers from

    11

    sites

    with

    annual doses

    greater than

    0.5,l

    .O,

    2.0,3.0,4.0,

    and 5.0 rem in

    1985

    and

    1989.

    The data include both u t i l iperson-

    nel

    (UT)

    and total personnel

    (TO)

    which includes

    contractors. Figure

    4.2

    (also from the same report)

    shows the percentage of u t i l i personnel and total

    personnel

    with

    annual doses greater than these dose

    values for the same two years. The contractor. doses

    are only those reported by the individual utilities and

    may not reflect their total dose @e. he sumof doses

    received at two or more sites).

    Figure

    4.1

    Annual Side

    Doses

    fo r Utility Personnel

    (UT) and Total Plant Workers

    (TO) (11

    Responders)

    9

    Figure 4.2 Annual Site Doses for Utility Personne

    (UT) and Total Plant Workers (TO) fo r

    1985

    and

    1989

    There is a clear decrease in the number and percent

    age of both utility and total personnel above each

    dose value in

    1989

    relative to

    1985.

    No person ex-

    ceeded

    5

    rem yr'.

    About 8% (967)

    of the people at

    11sites had annual doses greater than2 em yf ' in

    1989.

    4.1.3 Cumulative Dose Administrative

    Guidelines

    The survey showed that 13 of the

    26

    responders had

    established some form of a cumulative dose guide-

    line, the most common being age times

    1

    rem. Four

    have a review or reference level based on age, or a

    cumulative lifetime value, for which individual doses

    would be tracked and interventionwould occur. Ten

    responders had not established a cumulative guide-

    line in

    1989

    but modwere in the process of adopting

    one. We noted that seven responders had adopted a

    cumulativedose exemption procedure to exceed,

    which typically required the approval of a Vice Presi-

    dent, Director,

    or

    Plant Manager. The report stated

    that ...it

    is

    likely that

    in

    a few years most nuclear

    utilitieswill have in place some form of lifetime or

    cumulative dose guidance . In

    its

    December1991

    guidelines, INPO urged utilities to strive to meet the

    NCRP recommendation of a lifetime dose not to ex-

    ceed the workers age

    in

    rem.

    NUREG/CR-6112

  • 8/11/2019 NRC-2009-0279-0038

    24/79

    Sunrey Results

    4.1.4 Cumulative Reported Doses for

    1989

    Figure4.3 (reproduced from the EEI Report) shows

    the number of personnel, from

    19

    responder

    sites

    in

    1989,with

    cumulative doses in the categories

    25-50,

    50-75,75-100,100-150,nd

    >

    150 rem for utility and

    contractor personnel. TheEEIReport does not show

    how many individuals exceed a lifetime dose of their

    age in rem, but rather, the number of workers younger

    and older than50 that appeared in each cumulative

    dose interval.

    100

    n so

    6 - 7 s

    s . 1 ~ im-m

    Daecawm(rrm)

    Figure

    4.3

    Cumulative Site Doses for Utility and

    Contractor Personnel for

    1989

    (19Responders)

    Of this total worker population, less than

    50 utility

    and

    contractor personnel younger than50 had lifetime

    exposures greater than50 rem. Other findings on

    cumulative doses were:

    1)

    no

    utility

    worker had life-

    time doses greate-r han

    75

    rem, and

    2)

    several con-

    tractor personnel had lifetime doses greater than75

    rem, and a couple had more than150 em in 1989.

    4.1.5

    Figure

    4.4

    (reproduced from the EEIReport)shows

    the projected number of personnel from

    14

    responder

    sites anticipated to have cumulative doses in the

    same dose categories listed in Section4.1.4.These

    numbers are for both utility and contractor personnel

    projected from past data trends

    out

    to

    1994.

    Projected Cumulative Doses fo r1994

    Figure

    4.4

    Projected Cumulative Site Doses fo r

    1994

    Utility and Contractor Personnel

    (14Responders)

    If

    these projections are realistic, less than

    17

    workers

    younger than

    50

    would have cumulative doses greater

    than

    50

    rem

    in 1994.

    Also, no utility or contractor

    personnel are expected to have a lifetime dose

    greater than100 rem. The authors of theEEI report

    extrapolated this data to the entire nuclear industry If

    we assume that the

    15

    esponders represent one-

    fourth of the industry, we might expect about600

    workers

    with

    lifetime doses over

    50

    rem in

    1994,with

    about one-fourth of them (e 150, robably all con-

    tractors) over

    75

    rem and one-tenth of them (e

    60

    contractors) over

    100

    rem.

    4.1.6

    Effects of Changing the Annual

    Dose Guidance

    The

    EEI

    questionnaire asked:

    If

    all utilities adopted

    Uniform Site Annual Whole Body Dose Equivalent

    Administrative Limits (or guidance values), set at the

    following values, what difficulties, additional costs, col-

    lective dose increases, and AIARA effects do you see

    occurring: 4 em, 3 em, 2.5 rem, 2 em, 1 rem,

    0.5

    rem? The responses o this question were varied,

    and complicated by the fact that a similar question

    was asked:

    If

    NRC lowered the

    10

    CFR

    20

    annual

    committed effective dose equivalent limit to the follow-

    ing values, what do you see occurring:

    4,3,2.5,2,1,

    0.5

    rem? The following conclusions were drawn from

    the responses:

    NUREG/CR4112

    10

  • 8/11/2019 NRC-2009-0279-0038

    25/79

    Survey Results

    1.

    2.

    3.

    4.

    None of the seventeen responders felt that an

    annual dose limit of4 rem would affect operations

    significantly. (Ten felt the effect would be minimal;

    seven said very minor.)

    According to seven responders, an annual limit of

    3

    rem isachievable, but the contractor's workforce

    would have to be expanded.

    At

    2

    rem yf',

    two

    of five responders felt the limit

    was achievable. One responder felt the limit was

    possibly achievable, and

    two

    felt

    it

    would signifi-

    cantly affect operations. An example given was

    the lack of a qualified labor pool to work outages.

    At 1 rem yr', all responders felt operations would

    be ...extremely difficult, if not impossible.

    4.1.7

    Effects of Establishing

    a

    Cumula-

    tive Dose Limit

    The questionnaire asked,

    If

    a cumulative or lifetime

    effective whole body dose limit were imposed by the

    NRC, what difficulties, additional costs, collective

    dose increases, and ALARA effects...do you see

    occurring at 3 x'age,2 x age, 1.5 x age, 1x age and

    0.5 x age? Because many of the21 responders

    already had adopted a 1

    x

    age administrative guide-

    line and had experience with its effects, the responses

    were more consistent than those on other questions

    about anticipated effects:

    1.

    2.

    3.

    Most responders felt that minimal mpact would

    occur for ut i l ipersonnelwith a cumulative limit of

    3

    x age, 2 x age, and 1.5x age; at a level of

    0.5

    x

    age, most saw substantial effects.

    The majority of responders felt that minimal im-

    pact would occur for contractor personnel at

    3

    x

    age, and about half felt that there would be mini-

    mal impact at2 x age.

    At a cumulative limit of

    1

    x age, 11 responders

    saw minimal impact on the numbers ofu t i l i

    personnel; the 10 other responders mentioned

    impacts, such as scheduling problems, lack of

    critical plant specialists, increased personnel and

    associated dose for certain

    jobs,

    and additional

    costs, e.g., source term reduction modifications/

    operations, radiation protection, and salaries.

    11

    4.

    At a cumulative limit of 1x age, only 1 responder

    predicted l i l e effect on contractor personnel;20

    responders felt there would be impacts. The

    same impacts as those listed in

    3.

    would occur,

    but to a greater degree.

    5.

    At the level of age times

    0.5,

    most responders

    expected substantial effects on utility personnel

    and all but

    two

    see substantial effects for contrac-

    tor personnel.

    4.2 Department of Energy (DOE)

    Report

    4.2.1

    Cost

    Impact

    Based on responses from

    37

    DOE

    contractors

    (-

    60%),

    the projected costs for all sites combined for

    a 20 mSv (2 rem) annual limit withouta doubling of

    the neutron quality factor, and with a doubling of the

    neutron quality factor are as follows:

    NUREGCR-6112

  • 8/11/2019 NRC-2009-0279-0038

    26/79

    Survey Results

    Personnel

    Costs

    Modification

    Costs:

    Initial

    Annual

    Initial

    Annual

    Radiation Protection Costs:

    Increased Collective Dose

    Neutron Qu ali i Factor of 10

    Neutron Qualitv Factorof 20

    $11M $15M

    $279M

    $ 3M

    $369M

    $

    4M

    $13M

    $

    5M

    103

    person-rem

    $17M

    $ 7M

    243 person-rem

    As noted in Section 3.1.2, the estimates do not in-

    clude the RockyFlats plants and LosAlamos National

    Laboratory, which have significant neutron exposures

    and collective doses. In addition, the costs associ-

    ated

    with

    more restrictive Annual Limits on Intakes

    (ALI) for intakes of radioactive materials and the use

    of committed effective dose equivalent are not fully

    represented.

    4.2.2 Annual Reported Doses, 1978 to

    1988

    Figure 4.5 (reproduced from the DOE report) shows a

    downward trend in the average annual dose equiva-

    lent for DOE personnel

    with

    measurable exposures

    from 1985 to 1988.

    200

    160

    100

    60

    a

    Figure

    4.5

    60

    e r e 2

    8s 04 85 m

    m w 8 a

    Yew

    Average Annual Dose Equivalent

    for

    DOE

    Workers with Measurable

    Exposure, 1978-1988

    NUREG/CR-6112 12

    The average dose per worker, with measurable expo-

    sure, was typically less than 2mSv yrl (200 mrem

    yf'),

    which is well below both the DOE annual limit of

    50

    mSv

    yf '

    (5

    rem yf') and the proposed 20mSv

    y f '

    (2 rem

    yf').

    The recent decreases are attributable to

    DOES continuingALARA efforts and changes inits

    mission.

    Figure 4.6 (taken from the DOE Report) shows the

    total number of DOE employees and

    visitors

    exceed-

    ing 2.0,l .O, and 0.5 rem annually from 1978 to 1988.

    Number

    of Individdo

    ( I

    1000)

    s

    '

    .

    -/iJz \

    t \ I

    2 -

    l.0 n m

    1 -

    2 0 mm

    -

    0

    1978 79 80

    81

    82

    83

    84 85 88 87 lS

    Year

    Figure4.6 Number

    of

    DOE Employees and annual

    dose 1978-1 988

  • 8/11/2019 NRC-2009-0279-0038

    27/79

    Survey Results

    In 1988, the total number of

    DOE

    personnel and visi-

    tors exceeding

    -

    2.0,l

    .O,

    and

    0.5

    rem was 35,548,

    and 1,862, respectively. If the decreasing trend in

    annual doses continues, a very small percentage

    (5rem

    0

    >2rem 331 >1 rem 3,101

    Number of Employees with Lifetime Dose Greater Than Age in Rem: 178

    Number of Employees with Measurable Dose: 24.098

    Annual Collective Dose: 10.915

    Table 5.5

    1993

    Exposure Experience (estimated)

    Number of Employees with Annual Doses:

    >5rem 0 >2rem 1000 >1 rem

    Number of Employees with Lifetime Dose Greater Than Age in Rem: 500

    Number of Employees with Measurable Dose:

    Annual Collective Dose:

    Nuclear Power Reactor Comments

    1.

    Two rem yrl is a challenge but achievable with

    management support.

    1

    rem yrl

    will

    require major

    modifications and increase in personnel (espe-

    cially for older facilities >15 years).

    2. LWRswill not be ableto operate with a 1 remyri

    limit.

    3. Facility modificationsshould not be necessary;

    specialized tasks or maintenance evolutions may

    result in higher doses for a few individuals &e.,

    10-1

    5),

    more frequent TLD processing may be re-

    quired, outage contractors may be unavailable for

    work due to dose restrictions.

    4. A limit of cumulative age, 3 rem yrl not to ex-

    ceed 10 rem in

    5

    years is workable. We need

    flexibility.

    5. We are attempting to limitHP Techs to

    ~1

    rem for

    1990: it could have been done in 1989. A few

    (contractor) employees have> rem than years

    may be put out of work. Initial approach to

    < 1

    rem yri will probably be to hire more people.

    6. Costs are extremely difficult to assess.

    7. The nuclear power facilities have not provided an

    informed, representative response to the question-

    naire.

    8. We recognize that the current regulatory limits do

    not provide a total lifetime dose limitation other

    than the defacto limit of5 rem yr' and, therefore,

    theoretically allows significant lifetime dose. If the

    regulatory limits need updating, the annual dose

    limits should not be changed, and a lifetime dose

    limit should be instituted equivalent to the NCRP

    recommendation of age

    =

    rem, with the proviso

    that persons who have already exceeded this limit

    be provided a special annual limit of1-2 rem.

    NUREG/CR-6112 26

  • 8/11/2019 NRC-2009-0279-0038

    41/79

    Questionnaire Results

    9. The use of administrative dose limits established

    below regulatory dose limits should be considered.

    10. Two rem yr ' limit would be difficult and costly, but

    achievable for utility workers. However, for con-

    tract personnel

    it

    would be very difficult and ex-

    ceedingly costly.

    11.

    For those individuals who would exceed the life-

    time limit of age in rem, a 2 rem yf ' limit would be

    necessary n orderto maintain their employment

    within the industry.

    12. The number of the more highly exposed contrac-

    tor staff working our outages ranges from 50-1

    00,

    each receiving1-2 rem per outage. Since the

    contractor staff works up

    to

    four to five outages

    per year, each of the more highly exposed work-

    ers becomes restricted by year's end under the

    current administrative dose limits of approximately

    4

    rem yf'. [Note that most of the contractor staff

    do not have a high lifetime dose (e.g., 0.2-0.5 x

    age in rem), as their employment has not always

    been in the higher dose work activities.

    13. If lower regulatory dose limits were instituted, the

    contractor companies would be forcedto hire

    more temporary staff, perform more training,

    charge higher rates, and, as a result, increase the

    financial cost. More importantly, this would result

    in increased collective dose due to using a larger

    and less skilled workforce. Likewise, we would

    incur an increase in our company Health Physics

    and support stars dose since we would be su p

    porting a larger, less skilled radiation worker force.

    In addition, the use of more temporary, less

    skilled workers also increased he probability of

    personnel error, which

    is

    a decrease in nuclear

    safety for both the co-workers and the general

    public.

    14. In the process of setting new regulatory dose lim-

    its,

    it

    is important o understand the dose limitation

    system typically in use at nuclear facilities restricts

    actual doses to approximately

    80

    percent of the

    regulatory imits; i.e., administrative imits are set

    by the utilities well below the regulatory limits.

    The use of administrative dose limits provides a

    safety margin designed to help the worker avoid

    exceeding regulatory limits. Ifthe NRC regulatory

    limit were 2 rem yr', nuclear facilities would

    essentially be required to set administrative imits

    in the rangeof 1.5 rem yr'.

    15. In addition to regulatory and administrative dose

    limits, the nuclear industry has achieved

    successes in steadily reducing individual, collec-

    tive, and lifetime accumulated dose to

    As

    LowAs

    Reasonably Achievable(AURA). In light of the

    entire system of dose limitation and

    A U R A

    prac-

    tices, we believe current annual dose limits under

    the revised 10 CFR 20 provide appropriate and

    adequate worker protection. In addition, an

    A U R A

    costhenefit analysis has not been per-

    formed, which indicates that reductions in the

    individual's annual dose ustify the expected in-

    crease in collective dose.

    16. If reduced dose limits must be instituted, we be-

    lieve that the important parameter to control

    should be lifetime dose, not annual dose. A modi-

    fied lifetime limit similar to the National Council on

    Radiation Protection and Measurements (NCRPs)

    recommendation would be appropriate. The mod-

    ification would beto allow a 1-2 rem yrl provision

    for persons who are approaching or have already

    exceeded this limit. We believe that the Interna-

    tional Commission on Radiological Protection

    (ICRP) recommendation of 10 rem in five years,

    with a yearly limit of

    5

    rem, would unnecessarily

    restrict our operational flexibility.

    17.

    It

    is noted that the dose risk models of BElR

    V

    do

    not make a distinction between the risk for chronic

    exposures based on annual dose rates which vary

    from 2-5 rem yr', i.e., risk associated with chronic

    exposure is primarily a function of total dose.

    Therefore, risk associated

    with

    current regulatory

    dose limits could b